Piercing Strategies’ goal is to provide professional qualitative subject matter expert advice and counsel to ensure federal contractors comply fully with their complex equal employment opportunity and affirmative action obligations. These services are based on a comprehensive and thorough understanding of OFCCP laws, regulations and policy directives. Piercing Strategies’ assessments are comprehensive examinations designed to pinpoint potential regulatory problems federal contractors may experience in implementing their contractual obligations. Our services are designed to answer critical corporate risk-assessment questions such as:
- What are the Affirmative Action Program (AAP) requirements for federal contractors?
- What AAP alternatives are available for implementation?
- Is the AAP internal audit and reporting system effective in identifying problem areas?
- Have AAP problem areas been correctly identified and timely corrected?
- What are the recordkeeping requirements (e.g., personnel or employment records, race, ethnicity, and gender identification, adverse impact evaluations, etc.) for federal contractors?
- Are impact ratio analyses properly and timely conducted on all personnel activities?
- Are compensation analyses properly and timely conducted on employees in the workforce?
- Have jobs been listed with an appropriate employment service delivery system?
Services provided by Piercing Strategies include:
- AAP Development
- Customized AAP development based on a contractor’s workforce.
- AAP Risk Assessment
- Analyses of existing AAP implementation, including supporting personnel activity and compensation data to determine compliance status with OFCCP regulatory requirements.
- Compliance Audit Support and Risk Assessment:
- Pre-audit Risk Assessment – An AAP review designed to pinpoint and correct potential desk audit problems and onsite issues.
- Pre-audit Personnel Activity Records Assessment – A records management assessment of applicants, hires, promotions, and terminations to pinpoint and correct potential desk audit problems and onsite issues.
- Pre-audit Compensation Analysis – An examination of pay policies and practices designed to pinpoint and correct potential desk audit problems and onsite issues.
- Corporate Diversity and Risk Management Global Assessment
- A corporate AAP review designed to pinpoint and correct potential problems at the headquarters and establishment levels.
- Personnel Activity Records Assessment – A records management assessment of applicants, hires, promotions, and terminations to pinpoint and correct potential problems at the headquarters and establishment levels.
- Compensation Analysis – An examination of pay policies and practices designed to pinpoint and correct potential problems at the corporate headquarters and establishment levels.
- Functional Affirmative Action Program (FAAP) Assessments and Implementation Support
- A qualitative review and analysis of existing corporate and establishment-level AAP organizational structures.
- Staff preparation and consultative assistance in agreement negotiations for a corporate AAP structure.
- Monitor, update and renewal support for FAAP agreements.
- AAP/EEO Staff Training:
- Staff training for AAP/EEO professionals and Human Resources Managers on OFCCP’s regulatory requirements, including AAP development and implementation, recordkeeping requirements, impact ratio assessments, etc.
- Staff training for non-AAP/EEO professionals, first-line supervisors, department and line managers, etc. on a contractor’s responsibilities and obligations under OFCCP’s laws.
Piercing Strategies is also available to provide complaint investigative services.